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Follow-Up: National Laboratory Certification Program (NLCP) Shares Information on the Updated Custody and Control Form (CCF)

Further to First Advantage’s Blog on the update to the CCF posted on August 19, 2020 at  the NLCP has shared the following notice. Please keep in mind that the comments below related to oral fluids testing relate only to federal testing because at this point in time DOT has not authorized oral fluids for DOT drug testing. However, the 2017 CCF can continue to be used through August 30, 2021 for DOT urine drug testing.  After that date, if a laboratory receives the 2017 CCF, the laboratory must obtain a statement of correction/Memorandum For Record/MFR from the collector if an expired federal form is used by the collector in order to test and report the results.

If and when there are laboratories approved for oral fluids testing, a federal agency (testing federal employees)  that wishes to use oral fluid laboratory-based testing must use the 2020 CCF for oral fluids testing.

ATTENTION: HHS-Certified Laboratories, Applicant Laboratories, and NLCP Inspectors

 Subject: Implementation of the 2020 Federal Custody and Control Form (CCF) 

HHS-certified laboratories: Please forward this email and attachment to Medical Review Officers (MROs), collection sites, clients, and other service providers for federal workplace drug testing programs.

Links to each referenced document are included within this message.

The Office of Management and Budget (OMB) has approved the 2020 Federal Custody and Control Form (CCF).  The 2020 Federal CCF may be used as a paper form or electronic form. The effective date of the Federal CCF is August 17, 2020, and the current expiration date is August 31, 2023.

The OMB Notice of Action is also available on the OMB website (or go to, click “ICR” in the top right hand corner, and search for 0930-0158).

The 2020 Federal CCF proof, Guidance for Using the 2020 Federal Custody and Control Form, and the Instructions for Completing the Federal CCF (for Urine Specimens and for Oral Fluid Specimens) will also be available on the SAMHSA website at

SAMHSA recommends that HHS-certified laboratories exhaust their current supplies of 2017 Federal CCFs before implementing the 2020 Federal CCF.  As stated in Question 3 of the Guidance for Using the 2020 Federal Custody and Control Form: OMB has granted an extension for using the 2017 Federal CCF until August 30, 2021.  The 2017 Federal CCF may be used for urine specimens only; this CCF is not authorized for use with oral fluid specimens.  As of August 30, 2021, the 2020 Federal CCF must be used for federally regulated specimens, and the test facility (laboratory or instrumented initial test facility, IITF) must treat the use of the 2017 Federal CCF for urine specimens as a correctable discrepancy.

Note:  At this time there are no HHS-certified oral fluid testing laboratories.  Please see the certified laboratory list at

If you have any questions concerning this Notice, please contact the NLCP staff by email or phone (919) 541-7242.

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